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Author: M.J. Miller
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Nearly all U.S. income tax treaties include a "Limitation on Benefits" (LOB) Article that generally requires a resident of a foreign country that is party to a U.S. income tax treaty (a "treaty country") to have one of certain specified connections to such country (or possibly the United States or certain other treaty countries) in order to access such treaty. The LOB Article is intended to limit the ability of third-country residents to engage in "treaty shopping" by establishing legal entities in treaty countries with which they otherwise have no meaningful connection.The LOB Article includes a number of objective tests. The common objective tests include (1) a public company test, (2) an ownership and base erosion test, (3) an active trade or business test, and (4) in some cases, a derivative benefits test.
Author: M.J. Miller
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Nearly all U.S. income tax treaties include a "Limitation on Benefits" (LOB) Article that generally requires a resident of a foreign country that is party to a U.S. income tax treaty (a "treaty country") to have one of certain specified connections to such country (or possibly the United States or certain other treaty countries) in order to access such treaty. The LOB Article is intended to limit the ability of third-country residents to engage in "treaty shopping" by establishing legal entities in treaty countries with which they otherwise have no meaningful connection.The LOB Article includes a number of objective tests. The common objective tests include (1) a public company test, (2) an ownership and base erosion test, (3) an active trade or business test, and (4) in some cases, a derivative benefits test.
Author: Desiree Auer
Publisher: Linde Verlag GmbH
ISBN: 3709411602
Category : Law
Languages : en
Pages : 496
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Book Description
A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
Author: Primitivo Mijares
Publisher:
ISBN: 9781523292196
Category :
Languages : en
Pages : 430
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Book Description
Author's Foreword This book is unfinished. The Filipino people shall finish it for me. I wrote this volume very, very slowly. 1 could have done with it In three months after my defection from the conjugal dictatorship of Ferdinand and Imelda Marcos on February 20.1975. Instead, I found myself availing of every excuse to slow it down. A close associate, Marcelino P. Sarmiento, even warned me, "Baka mapanis 'yan." (Your book could become stale.)While I availed of almost any excuse not to finish the manuscript of this volume, I felt the tangible voices of a muted people back home in the Philippines beckoning to me from across the vast Pacific Ocean. In whichever way I turned, I was confronted by the distraught images of the Filipino multitudes cryingout to me to finish this work, lest the frailty of human memory -- or any incident a la Nalundasan - consign to oblivion the matters I had in mind to form the vital parts of this book. It was as if the Filipino multitudes and history itself were surging in an endless wave presenting a compelling demand on me toSan Francisco, California perpetuate the personal knowledge I have gained on the infamous machinations of Ferdinand E. Marcos and his overly ambitious wife, Imelda, that led to a day of infamy in my country, that Black Friday on September 22, 1972, when martial law was declared as a means to establish history's first conjugal dictatorship. The sense of urgency in finishing this work was also goaded by the thought that Marcos does not have eternal life and that the Filipino people are of unimaginable forgiving posture. I thought that, if I did not perpetuate this work for posterity, Marcos might unduly benefit from a Laurelian statement that, when a man dies, the virtues of his past are magnified and his faults are reduced to molehills. This is a book for which so much has been offered and done by Marcos and his minions so that it would never see the light of print. Now that it is off the press. I entertain greater fear that so much more will be done to prevent its circulation, not only in the Philippines but also in the United States.But this work now belongs to history. Let it speak for itself in the context of developments within the coming months or years. Although it finds great relevance in the present life of the present life of the Filipinos and of Americans interested in the study of subversion of democratic governments by apparently legal means, this work seeks to find its proper niche in history which mustinevitably render its judgment on the seizure of government power from the people by a lame duck Philippine President.If I had finished this work immediately after my defection from the totalitarian regime of Ferdinand and Imelda, or after the vicious campaign of the dictatorship to vilify me in July-August. 1975, then I could have done so only in anger. Anger did influence my production of certain portions of the manu-script. However, as I put the finishing touches to my work, I found myself expurgating it of the personal venom, the virulence and intemperate language of my original draft.Some of the materials that went into this work had been of public knowledge in the Philippines. If I had used them, it was with the intention of utilizing them as links to heretofore unrevealed facets of the various ruses that Marcos employed to establish his dictatorship.Now, I have kept faith with the Filipino people. I have kept my rendezvous with history. I have, with this work, discharged my obligation to myself, my profession of journalism, my family and my country.I had one other compelling reason for coming out with this work at the great risks of being uprooted from my beloved country, of forced separation from my wife and children and losing their affection, and of losing everything I have in my name in the Philippines - or losing life itself. It is that I wanted to makea public expiation for the little influence that I had . . . .(more inside)
Author: Mohammed Bedjaoui
Publisher: New York : Holmes & Meier
ISBN: 9780841905887
Category : Business & Economics
Languages : en
Pages : 287
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Book Description
Author: Amy Blackwell
Publisher: Sourcebooks, Inc.
ISBN: 1402233426
Category : Law
Languages : en
Pages : 370
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Book Description
The Essential Law Dictionary is an essential up-to-date legal reference, containing over 3,000 entries explaining legal language that can often be hard to understand, even for lawyers. This book focuses on defining the terms that people today are most likely to encounter when dealing with the law. The definitions are clear, concise, and easy-to-understand. Whether you are a lawyer, a law student, or a layperson, this handy reference will help you understand the precise meaning of any legal term.
Author: Ghazi bin Muhammad (Prince of Jordan.)
Publisher:
ISBN: 9781903682838
Category : Islam
Languages : en
Pages : 0
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Book Description
Written by a number of Islamic religious authorities and Muslim scholars, this work presents the views and teachings of mainstream Sunni and Shi’i Islam on the subject of jihad. It authoritatively presents jihad as it is understood by the majority of the world’s 1.7 billion Muslims in the world today, and supports this understanding with extensive detail and scholarship. No word in English evokes more fear and misunderstanding than "jihad." To date the books that have appeared on the subject in English by Western scholars have been either openly partisan and polemical or subtly traumatized by so many acts and images of terrorism in the name of jihad and by the historical memory of nearly 1,400 years of confrontation between Islam and Christianity. Though jihad is the central concern of War and Peace in Islam: The Uses and Abuses of Jihad, the range of the essays is not confined exclusively to the study of jihad. The work is divided into three parts: War and Its Practice, Peace and Its Practice, and Beyond Peace: The Practice of Forbearance, Mercy, Compassion and Love. The book aims to reveal the real meaning of jihad and to rectify many of the misunderstandings that surround both it and Islam’s relation with the “Other.”
Author: Leon Ma Guerrero
Publisher: Guerrero Publishing
ISBN: 9719341874
Category : Nationalists
Languages : en
Pages : 539
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Book Description
Author: Carl Schmitt
Publisher: Telos Press Publishing
ISBN: 9780914386308
Category : Law
Languages : en
Pages : 372
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Book Description
Describes the origin of the Eurocentric global order, which Schmitt dates from the discovery of the New World, discusses its specific character and its contribution to civilization, analyzes the reasons for its decline at the end of the 19th century, and concludes with prospects for a new world order. It is a reasoned, yet passionate argument in defense of the European achievement, not only in creating the first truly global order of international law, but also in limiting war to conflicts among sovereign states, which in effect civilized war.
Author: Christian A. Conrad
Publisher: Springer Nature
ISBN: 3030988430
Category : Business & Economics
Languages : en
Pages : 470
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Book Description
In this textbook we examine the extent to which moral values play a role as productive forces for companies and the economy as a whole, and explores the effect of ethical and unethical behavior at both levels. We show how ethics improves productivity, and provide specific ethics tools for practical application for both students and managers. Stemming from an overall interdisciplinary approach, this textbook fills a gap in the literature on ethics in business. Following a textbook structure, we first derive knowledge from scientific studies that are relevant for students, and then summarize the results. We explain ethical assessment approaches, and then provide an ethical assessment of economic behavior using case studies. Roleplaying and games are used to explain the behavior of people in relation to ethics. The 2nd edition has been completely revised and expanded to include new findings from the behavioral sciences (psychology, social psychology, sociology and behavioral economics). In particular, the research on emotions, motivation and group behavior have given rise to many new impulses in business ethics. In addition, new case studies and new chapters were included, like Politics and Morality, Theories of Justice, Global Ethics, and Institutions as Solutions to Specific Game Situations (game theory). This book is important for students and researchers as well as policymakers and business executives due to its focus on applications.
Author: Will Bradley
Publisher: Tate
ISBN:
Category : Art
Languages : en
Pages : 494
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Book Description
"This reader gathers together an international selection of artists' proposals, manifestos, theoretical texts and public declarations that focus on the question of political engagement and the possibility of social change"--Back cover.
